United States securities and exchange commission logo

                              November 3, 2022

       Dinggui Yan
       Chief Executive Officer
       Jiayin Group Inc.
       18th Floor, Building No. 1
       Youyou Century Plaza
       428 South Yanggao Road
       Pudong New Area, Shanghai 200122
       People's Republic of China

                                                        Re: Jiayin Group Inc.
                                                            Form 20-F for the
fiscal year ended December 31, 2020
                                                            Filed April 30,
                                                            Form 20-F for the
fiscal year ended December 31, 2021
                                                            Filed April 29,
                                                            File No. 001-38806

       Dear Dinggui Yan:

              We have reviewed your May 3, 2022 response to our comment letter
and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to these comments, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       April 19, 2022 letter.

       Form 20-F for the fiscal year ended December 31, 2021

       Item 3. Key Information, page 7

   1.                                                   We note your disclosure
on page 1 that    China    or the    PRC    refers to the People   s
                                                        Republic of China,
excluding, for the purposes of your annual report only, Hong Kong
                                                        and Macau, your primary
reference to China and or the PRC in your risk factors with
                                                        regard to operating,
regulatory, legal, and governmental authorities and the flow of capital
                                                        contributions/loans and
or dividends/distributions through Geerong (HK) Limited, your
 Dinggui Yan
FirstName  LastNameDinggui   Yan
Jiayin Group  Inc.
Comapany 3,
November   NameJiayin
              2022     Group Inc.
Page  2    3, 2022 Page 2
FirstName LastName
         wholly-owned subsidiary located in Hong Kong, Jiayin Group, Inc., your
         subsidiaries and the consolidated VIE as reflected in your diagram on
page 11. Please
         revise your definition of    China or the PRC    to include Hong Kong
and Macau and to
         clarify that the    legal and operational    risks associated with
operating in China also apply
         to your operations in Hong Kong. The definition may clarify that the
only time that
            China or the PRC    does not include Hong Kong or Macau is when you
are referencing
         specific laws and regulations adopted by the PRC. If it does, please
revise your disclosure
         to discuss any commensurate laws or regulations in Hong Kong, if
applicable, and any
         risks and consequences to the company associated with those laws and
regulations. As
         one example, your enforceability of civil liabilities discussion
should discuss the
         enforceability of civil liabilities in Hong Kong. Please provide us
with your proposed
2.       We note your response to prior comment 5. Please disclose if you
consulted with counsel
         on any individual permission or approval that you or your
subsidiaries, and the VIE and
         its subsidiaries are required to obtain from the China Securities
Regulatory Commission
         (CSRC), Cyberspace Administration of China (CAC) or any other
governmental agency
         that is required to approve the VIE   s operations and your other
subsidiaries' operations
         and if so, please identify counsel in your disclosure. Please provide
us with your
         proposed disclosure.
3.       Also in your response to prior comment 5 and added disclosure on page
20, we note that
         you indicate that you do not believe that you are not required to
obtain any approval from
         the CAC or other PRC government authorities under PRC law in
connection with a future
         offering of your securities to foreign investors. Based on your more
detailed disclosures
         that follow on page 21 and risk factor disclosure on page 54, it
appears that this statement
         may be in error. Please confirm for us that you intended to disclose
that you do not
         believe that you are required to obtain such approvals. If so,
represent to us that you will
         correct in future filings. If not, reconcile your belief with those
disclosures on page
         21 and provide us revised disclosure that describes the approvals you
must receive.
Item 5. Operating and Financial Review and Prospects
B. Liquidity and Capital Resource, page 114

4.       We acknowledge your response to prior comment 1. Although you indicate
         you changed all references to "our consolidated VIE" to "the
consolidated VIE" in your
         2021 Form 20-F, we note that you continue to refer to "our
consolidated variable interest
         entities" in the second and third paragraphs of this disclosure on
page 114. Please
         represent to us that in future filings you will modify this disclosure
consistent with your
         prior response.
      You may contact Michelle Miller at 1-202-551-3368 or Mark Brunhofer at
3638 with any questions.
 Dinggui Yan
Jiayin Group Inc.
November 3, 2022
Page 3

FirstName LastNameDinggui Yan    Sincerely,
Comapany NameJiayin Group Inc.
                                 Division of Corporation Finance
November 3, 2022 Page 3          Office of Finance
FirstName LastName